Can ''Personnel Manual'' Create An Employment Contract ?

Byars v. City of Austin, 910 S.W.2d 520 (Tex. App.--Austin 1995, writ denied) involved a breach of contract claim. The issue in Byars was whether the personnel manual expressly altered the at-will-employment status of a City employee. See id. In Byars, the Court held that the manual did not alter the at-will-employment status of the plaintiff and the employee did not have a protected property interest in employment that would entitle her to more procedural protection than she received. See id. at 524. The Byars decision held that the manual did not create an employment contract or limit the City's power to terminate an employee in any way. See id.